United States International Trade Commision Rulings And Harmonized Tariff Schedule
faqs.org  Rulings By Number  Rulings By Category  Tariff Numbers
faqs.org > Rulings and Tariffs Home > Rulings By Number > 1998 NY Rulings > NY NY183 - NY NY1865 > NY NY1845

Previous Ruling Next Ruling

NY D80512

August 12, 1998

CLA-2-39:RR:NC:SP:221 D80512


TARIFF NO.: 3919.90.5060

Mr. Jeff Holshevnikoff

Image World, S.A.

Interlink 782

P.O. Box 02-5635

Miami, FL 33102

RE: The tariff classification of printed self-adhesive vinyl sheets from Costa Rica and Mexico.

Dear Mr. Holshevnikoff:

In your letter dated July 21, 1998, you requested a tariff classification ruling.

Image World, S.A., of Costa Rica imports vinyl sheets (36" by 150' rolls), clear plastic over-laminate (also 36" by 150' rolls) and ink. These products are all made in the United States. Image World, using American made printing machinery, then electrostatically prints an image on the vinyl. Using American made laminating machinery, Image World then applies the laminate as a protective layer. A similar operation is performed in Mexico, except that the printed image is applied through screen printing. In both instances, the printed rolls are then cut to specific size and shipped back to the United States in boxes. The printed panels are typically applied to the sides of buses and trucks for advertising or fleet marking.

The applicable subheading for the printed vinyl adhesive sheets will be 3919.90.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics...other. The duty rate will be 5.8 percent ad valorem.

Articles which are classifiable under subheading 3919.90.5060, HTS, which are products of Costa Rica are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations, if the GSP is renewed.

Alternatively, products which are classifiable under subheading 3919.90.5060, HTS, which are the products of Costa Rica are entitled to duty free treatment under the Caribbean Basin Economic Recovery Act (CBERA) upon compliance with all applicable regulations.

You provided a sample of film that has been printed with a bird. The printed sample is a product of Costa Rica, and upon compliance with applicable regulations, such film will be eligible for duty free treatment under the CBERA, or under the GSP, if the GSP is renewed.

However, it is not clear that all electrostatically printed film you plan to import from Costa Rica can be considered products of Costa Rica. The film itself is a product of the United States. In order for the printed film to be considered a product of Costa Rica, the film will have to have undergone a substantial transformation. You mention that the film will be used for bus and truck fleet identification. Merely printing company logos on a film does not substantially transform the film. Please provide samples and descriptions of the printed film.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Joan Mazzola at 212-466-



Previous Ruling Next Ruling

See also: